How to Set up a Maintenance Program that Will Keep FMCSA Happy

What do federal maintenance program requirements mean to you?

Many people are puzzled by what the Federal Motor Carrier Safety Administration is talking about in the maintenance regulations. In §396.3 it simply states that a carrier must have a program to “systematically inspect, repair, and maintain, or cause to be systematically inspected, repaired, and maintained, all motor vehicles and intermodal equipment subject to its control.”

This applies to all carriers, whether you have one truck or 20,000.

As far as actually establishing the specifics of the maintenance program, that is up to the carrier.

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The only other guidance the FMCSA provides is that parts and accessories (the ones required in the regulations) “shall be in safe and proper operating condition at all times.” The specifics about what “safe and proper” means are scattered throughout the regulations, but they are mostly found in Part 393 and Appendix G.

The effectiveness of a carrier’s maintenance program is “officially judged” during roadside inspections. This judging is especially important if you have just gotten your DOT number. All “new-entrant carriers” (carriers that have just gotten a DOT number) are subjected to a “new-entrant safety audit” after 6 to 18 months of operation. One component of this audit is calculating the new carrier’s out-of-service rate (what percentage of the time the carrier’s vehicles “fail” a roadside inspection). If it is too high, it will lower the carrier’s chances of getting lifted off new-entrant status.

Where do you start?

The first step is determining how often you should do maintenance inspections and preventive maintenance on your vehicle(s).

To get started, you can contact the original equipment manufacturer that built the vehicle. Most OEMs have inspection and preventive maintenance (PM) “schedules” available for the vehicles they build. These include recommended intervals (based on miles, hours run, and/or dates) and checklists (items that should be checked).

You should also establish “cut-off points” for major components that wear out. This is the point at which a part or component will be repaired or replaced. The starting point for these decisions needs to be the limits established in Part 393 of the FMCSA regulations, as well as Appendix G. If the regulations do not establish a cut-off point for a part or component, the OEM can usually provide this information.

Tires, brake adjusters, brake linings, fuel filters, and clutches are examples of parts and components that can have cut-off points assigned to them. The idea is to repair or remove the part or component before it creates a problem on the road. This may sound complicated, but it is much better than breaking down (or worse, causing a crash).

Next, set up the records

One key to compliance in this area is maintenance records. If you are audited, these records will be an important part of the audit as they show that you are “taking care” of your vehicle(s).

Carriers — here again, no matter how big or small — must have an “informational record” for each vehicle that includes:

Fleet number (if one is assigned)

Make, model, and year

VIN

Tire size

Owner (if not the carrier)

A maintenance schedule for the unit (a means to indicate when maintenance was last done and is to be done again)

The regulations also require that records of all inspection, maintenance, lubrication, repairs, and upcoming maintenance be kept for one year while the unit is in service, and for six months after the unit leaves service. So far all of this is covered in §396.3. The records can take any form the carrier wants; there are no “required forms” for documenting normal maintenance and repairs. A handwritten note describing what was done or a receipt from a truck shop would qualify as “maintenance records.”

The one exception is periodic (annual) inspections reports. They must contain specific information and be kept for 14 months, rather than 12.

You will want to set up and maintain maintenance records not just because they are required by the regulations, but because they can help you decide if your maintenance program is working. The records can also help you determine where you are having vehicle problems and how much it is really costing you to operate a specific piece of equipment.